COMMERCE BANCSHARES INC /MO/ — Director's Dealing 2004

Nov 22, 2004

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMMERCE BANCSHARES INC /MO/ (CBSH)
CIK: 0000022356
Period of Report: 2004-11-19

Reporting Person: KEMPER DAVID W (Director, Chairman of the Board, CEO)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2004-11-19	Common Stock	S	1648	$50.54	Disposed	974281	Direct
2004-11-19	Common Stock	S	3402	$50.53	Disposed	970879	Direct
2004-11-19	Common Stock	S	1000	$50.52	Disposed	969879	Direct
2004-11-19	Common Stock	S	1000	$50.51	Disposed	968879	Direct
2004-11-19	Common Stock	S	198	$50.5	Disposed	968681	Direct
2004-11-19	Common Stock	S	1648	$50.54	Disposed	967033	Direct
2004-11-19	Common Stock	S	3402	$50.53	Disposed	963631	Direct
2004-11-19	Common Stock	S	1000	$50.52	Disposed	962631	Direct
2004-11-19	Common Stock	S	1000	$50.51	Disposed	961631	Direct
2004-11-19	Common Stock	S	198	$50.5	Disposed	961433	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	10747	Indirect
Common Stock	1461	Indirect
Common Stock	18125	Indirect
Common Stock	18129	Indirect
Common Stock	5680	Indirect
Common Stock	18129	Indirect
Common Stock	1907208	Indirect
Common Stock	37998	Indirect
Common Stock	136699	Indirect
Common Stock	18117	Indirect